Title II FAQs

Title II of the Americans with Disabilities Act ensures that anyone with a disability has equal access to state and local government services such as public education, and it covers the accessibility of web content and digital applications. The updates in the new rule are a clarification stating that all digital course content needs to be accessible from the start when it is posted, rather than in response to a request for accommodation. Title II also defines WCAG 2.1 A and AA as the specific set of technical standards that must be met for content to be considered accessible. While the rule establishes specific technical standards and deadlines, the underlying legal obligation to provide accessible digital services is not new and is not suspended.

On April 17, 2026, the Department of Justice issued an extension of compliance date to April 26, 2027.  No other parts of the new rule have been changed at this time, so it is important to stay the course of making your materials accessible and to simply look at this extension as additional time to refine and complete accessibility goals. Per university policy, all digital content must meet accessibility standards as soon as practical. The university remains committed, despite this delay in enforcement, to ensuring that all students, employees, and members of the public have equitable access to digital materials. More details can be found at the Federal Register

Executive Memorandum 47, the university’s Information and Communication Technology Accessibility Policy, has been amended to include an effective date of April 26, 2027.  Faculty and staff should continue to work toward making their digital content accessible using available resources and guidance.

Reports about content that is not accessible should be directed to the content creator and/or IEC. On receipt of a report, the creator will be expected to seek guidance, if needed, about whether the content is or is not consistent with standards and remedy the content if needed (in consultation with IEC or other offices such as CTT or Academic Technologies). If IEC receives such a report, IEC will investigate whether the content meets accessibility guidelines or not, and if not, will work with the content creator to remediate the content. The focus will be on remediating that content to meet standards, not punishment of the content creator.

Disciplinary processes will be invoked in instances where there is a willful failure to remediate content. For example, if a person has been directed to make a change to how their content is posted, and they frequently publish content, the focus will remain on remediation if there are occasional errors in the content’s accessibility over time. But if a person refuses to publish their content in accordance with guidance for making that content accessible, their intentional refusal to comply with university policy will be addressed through disciplinary processes. This will most likely be IEC’s accessibility grievance process or discrimination/harassment grievance process.

Previously, when a student had an accommodation requiring accessible digital materials, instructors were given up to two weeks to make updates to course content. This approach put students with access needs two weeks behind in their courses. The proactive approach of starting with accessible documents allows for equal and timely access. Incorporating accessibility also increases usability for all users. While the rule establishes specific technical standards and deadlines, the underlying legal obligation to provide accessible digital services is not new and is not suspended.

Digital course content is accessible when it follows WCAG 2.1 A and AA guidelines. This involves using features in all digital programs (such as Microsoft Word, PowerPoint, Excel, PDFs, Video production software, Canvas, Google tools, etc.) that allow assistive technologies to move through the content. A few examples are using headers, the bulleted list feature, adding alt text for pictures, having captions in videos, etc. The CTT has created resources to help you learn how to make your content accessible. 

This is a final rule under the Americans with Disabilities Act, and it is already in effect. The April 26, 2027 deadline is merely the end of the stated grace period for compliance. The Department of Justice has made it clear that this is a civil rights obligation, not a temporary policy. While it’s natural to feel skeptical, this standard for how we create digital content won’t be going away. From a university perspective, accessible digital materials were a priority even before the Title II updates were announced because they help support the learning of all students.  Per university policy, all digital content must meet accessibility standards as soon as practical.

There are very few exceptions to Title II. Even if a document or website was created before the deadline, if it is edited or actively used after the deadline, it most likely needs to be compliant. If you think you qualify for an exemption, you need to have the exemption approved by IEC. 

This page has more information on specific exemptions that exist, but generally speaking they include: 

• Archived web content that was created before the deadline, will not be edited after the deadline, and exists in a specific space that is clearly marked as Archived.
• Preexisting electronic documents that are in conventional formats, were posted before the deadline, and do not continue to be actively used.
• 3rd party content posted without an existing contractual or licensing arrangement (for example, someone from the public responding to a social media post).
• Individualized conventional electronic documents about a specific person and password protected (for example, making comments on student work and uploading it to the Canvas grading interface)
• Preexisting social media posts. This means you’re not expected to go back and remediate your historical social media posts.

Exceptions require approval of the ADA compliance officer.  Reach out to IEC at access@unl.edu to find out if you qualify for an exemption.

It is generally not acceptable to create these so-called "Conforming Alternate Versions" unless there are technical or legal limitations on updating the original.   Additionally, this is not a best practice because the two versions tend to drift apart over time with only one getting updated.

You're not required to toss all your PDFs, but any PDFs you use for your course must meet accessibility guidelines. Unfortunately, many older or scanned PDFs are not accessible, and PDFs are more challenging to remediate than other document formats. For scanned PDFs of journal articles or book chapters, you can often find accessible versions through the libraries. The “don’t use PDFs” advice is really about avoiding inaccessible formats whenever possible. For example, for accessibility it is better to leave Word Documents and PowerPoints in their original file format rather than converting those document types into a PDF format. See this PDF Accessibility Checklist for more information on what is required to make a PDF fully accessible. 

Actually, anyone with Adobe Pro can edit pdfs, and it is now easy for anyone to grab content from PDFs with AI tools, so PDFs don’t lock down content. It is possible to share other document formats in a way that prevents others from editing your original version. One option put the document in OneDrive, then share using a View Only link. Another option is for instructors to load the file directly into Canvas where students can download a copy. 

Forms must be accessible, and fillable PDFs are a challenge to remediate. At UNL, we have other alternatives that are effective for replacing fillable PDFs. Common accessible options for forms include: Webforms on our website, Qualtrics, Microsoft Forms, NuRamp, or Canvas Quizzes (for classes). These forms have the added benefit of being able to more easily extract and use the data that are entered into the form.

DocuSign in particular is challenging to make fully accessible.  When creating a form, you'll want to use the Word accessibility checker when creating the original document and also run the Adobe accessibility checker once you export the document to PDF form.  However, the resulting signed document is often inaccessible since tag structures from the original are often not preserved and signature blocks are often rendered as images without alt text.

All actively used content needs to be digitally accessible. This means courses starting from Spring 2026 and going forward will need to meet Title II accessibility requirements. Courses prior to Spring 2026 are not being asked to be remediated and instead are planned to be archived. Instructors do not need to do anything to those previous courses at this time.

There isn’t a course-by-course audit happening right now, but Ally data are being shared with administrators to understand the current status of our courses and help ensure we are complying with the law. In some cases, administrators may use that data to reach out to individuals or units to ask that they work on improving their Ally score. If a student files a complaint or if there is a federal investigation or court case, the institution must be able to show that reasonable steps were taken to make course content accessible. If your course isn’t compliant, it could lead to barriers for your students and legal risk for the university. The focus is on the shared goal of making sure no one is excluded from learning, not on punishing instructors. 

The goal is to reach a 100% Ally score. It is important to note that there are a number of things that Ally can’t look for, so even a 100% doesn’t guarantee that your course is fully compliant. For example, Ally does not look at linked content, so you need to manually look at any files shared via OneDrive or Google Drive links. It is also not as robust of a tool for scanning uploaded documents as the checkers built into programs like Adobe and Microsoft, so it is recommended that you run the accessibility checkers within those programs before uploading documents. 

We are also aware that there are situations where Ally incorrectly flag things that are not problematic. For example, there are reports of Ally flagging contrast issues when black text is on a white background. You can’t improve the contrast any more than that, so you should consider this a glitch with the Ally tool and move on. 

Ally is a very helpful place to start, but no automated software can identify all accessibility issues. For example, Ally will tell you whether a PDF has had OCR run to create digital text, but it can’t tell you whether the resulting text is accurate, so you need to manually check after running OCR. Ally also doesn’t scan documents hosted on sites external to Canvas (e.g. documents linked through OneDrive or Google Drive, links to external textbooks or websites, etc.), quiz questions housed in banks, documents added to the course using a Libraries Resources link, or Excel documents. As you’re working with Ally, we recommend using these individual program checklists to make sure you’re catching everything. 

There is a known issue with PDF 2.0 + MathML documents not being correctly recognized by Ally and receiving lower scores than they should.  In all cases, the goal is accessibility, not the best Ally score, so you should proceed with the more accessible document.  If you find yourself in a situation similar to this, contact Institutional Equity and Compliance (IEC) at access@unl.edu and Information Technology Services (ITS) at nusupport@nebraska.edu to discuss the details. 

Yes. Regardless of the number of images, any image that conveys meaning or supports learning must include appropriate alternative text so students using screen readers can access the same information. Only truly decorative images can and should be marked as decorative. This is information is true not only for PPT and PDF, but all program types like Word, Excel, and Canvas.

You will need to include a long description of the image in addition to the alt text. Alt text is directly attached to the image in the HTML code and provides a brief explanation of the image content and purpose and based on the intent and context within the document. In addition, complex visual content like graphs and figures needs a full text description so that students using screen readers or other assistive technology can access the same information. To learn more, check out CTT's Guide for Complex Images, which offers practical guidance and even an image description generator. 

It can take a little bit of thinking, but it is possible to write alt text that doesn’t reveal the answer. Each time you write alt text, you will consider the use of the image and adjust your description accordingly – which includes not revealing the answer. The more you practice this, the easier it will get. Students with visual impairments may have access to additional support through their accommodation. If you need help figuring out how to write good alt text for quiz questions, reach out to your instructional designer.

Adding alt text for screenshots takes practice. Screenshots are one of the few cases where images of text are appropriate because they are necessary for instruction (e.g., showing a system interface). The goal is not to describe every visual detail, but to capture the purpose of the screenshot. Focus your alt text on the key action, label, or outcome (e.g., “Canvas settings page showing the ‘Publish’ button highlighted”). If the screenshot contains a lot of important text or multiple steps, include that information in the surrounding content instead of relying on the image alone. When in doubt, IEC can help review or refine alt text to ensure it meets accessibility expectations. 

Not right now, but it might be included in an upcoming revision to the brand guide. Reach out to University Communications if you have questions regarding appropriate alt text for university content.

Provide captions for all photos and avoid putting text in photos. Ensure all videos have accurate captions. Use emojis where they make sense, but don’t go overboard with emojis since each emoji will be read out individually by a screen reader. Nobody wants to hear “Banging head on the wall” repeated 10 times. 

Yes. Student organizations are generally considered part of the institution’s digital presence, so their web and social media content is expected to meet the same accessibility standards under Title II.

Not entirely. Graphics with text are common on platforms like Instagram, but under Title II, important information should not be conveyed through images alone. If you use graphics with text, you should also provide the same information in accessible formats, such as writing the full message in the post caption and adding alt text when possible. A good rule of thumb is: if the text in the image matters, make sure it also appears as real, readable text in the post.

No. Instagram Stories lacks accessibility features. You can make posts to your Instagram feed instead.

No, only the Flagship has an account. This is not a social media platform university units should be using.

Generally, existing social media content posted before the deadline is considered “pre-existing” and does not automatically need to be remediated. However, if that content is still actively used, shared, edited, or otherwise interacted with after the deadline, it should be made accessible. 

There must be open or closed captions. Closed are preferable when possible, but only one type of caption is required.

When recording, verbally describe all key features of images. That way, the information will automatically be included in the captions and transcript. If the video is already recorded, you will need to add audio descriptions that include that information in addition to captioning.  MediaHub and YouTube support audio descriptions. 

Yes, the university regularly conducts audits of the UNL website and sends the reports to the people managing specific pages.  If you would like to see the report for your unit, contact the website manager for your unit or reach out to University Communications if you would like to be on the report list.

When possible, we recommend shifting CVs to web content. Otherwise, you need to make the files that are uploaded accessible. This could be handled by requiring the faculty to submit accessible versions. Word documents are easier to make accessible than PDFs so you may want to post those directly. If you choose to post PDFs, you should run the accessibility checker on the original Word document, use the “Export as Adobe PDF” option to create the PDF, then run the Adobe accessibility checker after the export. 

There is not currently an accessibility checking feature in UNL’s Newsroom. Newsroom stories are typically designed to be brief, consisting of a title and then body text. If you add any URLs to your newsroom story, please be sure to hyperlink descriptive text rather than sharing a raw URL. If you add an image to a newsroom story, ensure you provide a description in the “image description” box to capture alt text. 

If you're using software that’s widely adopted in your field but not officially supported by UNL, you’re still responsible for doing what you reasonably can to ensure students with disabilities can participate. That might mean offering alternatives, reaching out to vendors for accessibility info through the procurement process (ask them for their VPAT), or consulting with Institutional Equity and Compliance about developing an Equally Effective Alternate Access Plan (EEAAP) to accommodate students if the tool isn’t accessible. 

Yes, all course materials, including textbooks, do need to meet accessibility standards. Publishers are increasingly aware of these requirements, so the best first step is to ask them directly about their commitment to accessibility (like screen reader compatibility, keyboard navigation, alt text for images, and PowerPoints). Libraries can also help vet materials or find alternatives if needed. The libraries have information on their accessibility practices and course reserves, as well as contacts for their subject specialists. 

The accessibility rules apply to any content you require students to use as part of your course. If student-to-student work like peer review is required, the work that students produce should meet the standards. Similarly, if you share work created by previous students as an example, you may need to make edits to ensure accessibility. This is a great opportunity to introduce your students to the concept of digital accessibility which many of them will need to implement when they graduate and have jobs that involve creating digital materials. 

Going paper-only isn’t a realistic solution for most modern classrooms. The reason you’re making materials available digitally in the first place is likely because of the benefits for both students and for you as an instructor. Removing digital materials limits access for many students and makes your course harder to manage in the long run. Digital materials can actually increase accessibility, and many students now rely on screen readers, digital note-taking, and flexible formats to succeed. 

Additionally, many students with disabilities have accommodation plans that include digital access to course materials, so it is likely that you’ll end up needing to create accessible versions of your materials anyway. It’s often a lot easier to just give everyone access to your materials than to manage access for the students with that accommodation plan. 

Your instructional designer! You can find the instructional designer assigned to your college and reach out with your course accessibility questions. For help with non-course related documents, you can reach out to the Office of Institutional Equity and Compliance by emailing access@unl.edu or calling (402) 472-3417 .

The reason we aim to make course materials accessible proactively is because the ADA requires public institutions to ensure equal access to all students. The updated Title II ruling takes the stance that students with disabilities having to put in an accommodation request then wait for the instructor to make updates is not equal access to education. It produces significant learning delays that negatively impact the ability of students to complete their coursework. Also, many students don’t disclose their disabilities—whether due to stigma, lack of diagnosis, or uncertainty about their rights—so a reactive approach can leave them unsupported.

This doesn’t mean that accommodations will no longer be necessary, but ensuring that digital materials are accessible to begin with will reduce the number of students needing accommodations allowing our SSD office to focus on those with more specialized needs. 

Academic freedom gives faculty the right to determine the content, pedagogical approach, assignments, and assessment practices used in your courses. Title II puts no limits on these aspects of course design. You are still able to use whatever teaching materials you see fit, you just need to ensure that they meet specific technical standards to ensure that all students have equal access to the content you use for the course. If you feel that you are having to adjust your pedagogy meaningfully to comply with the law, you should reach out to the Office of Institutional Equity and Compliance for assistance.

Presentations that are not made available to students digitally are not directly covered by Title II, but we still recommend that you follow best-practices that support the learning of all students like using a large font size, ensuring high color contrast, and turning on live captioning within PowerPoint. 

Additionally, many students with disabilities have accommodation plans that include digital access to course materials, so you should be prepared to provide accessible versions of your materials if that happens. 

You can contact Institutional Equity and compliance about legal and policy issues by emailing access@unl.edu or calling (402) 472-3417

Making content accessible does take time and effort, especially at first. Remediation is much harder than making new documents accessible, so things will become much easier once you’ve worked through the backlog of your current documents. While the university is not providing direct compensation, the CTT offers a range of resources to help ease the process, including access to instructional designers who can consult on accessible course design and help identify practical strategies for compliance. Resources from across campus will also be collected at ada.unl.edu.  Departments are welcome to use their own budgeted funds if they wish to hire additional help for accessibility remediation or instructional support.